A California judge tentatively dismissed one of three pending cases between Pierce Bainbridge Beck Price & Hecht and its former partner Donald Lewis this week, concluding that Lewis’ contacts with California weren’t strong enough to establish personal jurisdiction.

While Lewis emailed a draft complaint to more than a dozen Pierce Bainbridge partners, some of whom were in California, Judge Patricia Nieto of the Los Angeles Superior Court ruled that it wasn’t enough of an anchor for personal jurisdiction under state law. The firm had argued that Lewis’ contacts met the standard of the so-called “effects test,” but the judge rejected that.